When a company transact with foreign entities, it is necessary for the company, its parent company and/or its subsidiary to submit (1) local file (detailed information necessary to figure out arm’s length price between related-parties), (2) Country-by-Country Report (country-by-country information of the activities of MNE (multinational enterprise) group) and (3) master file (information of the entire activities of MNE group) to the local tax authority.

The scope of this rule is broader than before, thus not only major enterprises but also small-to-medium-sized enterprises are required to prepare for this documentation. Transfer Pricing is a unique system for international taxation and very specialized field so that we provide consultation for documentation in cooperation with specialized attorneys, tax accountants and economists.